RENAISSANCE PRIVACY NOTICE – HEALTH FORMS & QUESTIONNAIRES
This Privacy Notice explains the use and processing of personal data by Renaissance Products Limited, a company incorporated in Ireland with registered number 176849 and whose registered office is at Renaissance House, Church Street, Howth, D13 V2N1 (“Renaissance”, “we”, “us”, “our”) when you provide such data to us via our Facial Consent Form, Peel Consent Form, Health Questionnaire and/or our Reaction Form (each a “Health Form” and together the “Health Forms”), whether issued to you by us directly or by the authorised retailer (“Authorised Retailer”) who supplied the product(s) and/or treatment(s) to which the relevant Health Form relates (“Product(s)”.
Renaissance is a processor (as this term is defined under data protection law) of personal data which is collected from you via the Health Form(s).
Renaissance is only responsible for, and this Privacy Notice only deals with, Renaissance’s own data protection and privacy practices. This Privacy Notice does not deal with the data protection or privacy practices of the Authorised Retailer(s) or any other third parties.
1 CONSENT
1.1 To the extent that the personal data which we collect about you comprises Health Data (as defined below), we rely on your explicit consent obtained from you via the relevant Health Form(s).
1.2 Your consent may be withdrawn at any time by contacting us using the Contact Us details below. This will not affect the lawfulness of any processing of Health Data carried out before consent is withdrawn. If consent is withdrawn:
- in respect of any Health Data provided by you in a Reaction Form, we may not be able to properly investigate the matter to which the Reaction Form relates;
- in respect of any Health Data provided by you in a Facial Consent Form, Peel Consent Form or Health Questionnaire, you may not be able to continue to receive treatments using the Product(s).
2 THE PERSONAL DATA WE COLLECT ABOUT YOU
2.1 Depending on the type of Health Form(s) which you are required to complete, we will process different kinds of personal data which we have grouped together as follows:
2.1.1 Contact Data includes name; address, phone number, email address, fax number, occupation, date of birth and occupation.
2.1.2 Health Data includes details of skin conditions such as wrinkles, acne, hyperpigmentation, photoaging, rosacea, dehydration, scars; details of any allergies; health information such as pregnancy, diabetes, cancer, high blood pressure, whether you are taking hormone therapy, the existence of cold sores, history of depression and/or whether or not you have received radiation treatment; information regarding your reaction to the sun; details of any treatments you have had from other physicians such as dermatologists and plastic surgeons; where you have had a reaction to a Product or treatment, details of the reaction.
2.2 We also collect, use and share aggregated data such as statistical or demographic data for various purposes. Aggregated data may be derived from personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
2.3 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you choose not to furnish this when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g. where we need your mailing address to send you a product you are looking to buy).
3 HOW WE COLLECT YOUR PERSONAL DATA
You may give us your personal data by filling in the Health Forms and providing them to us directly or, alternatively, to the Authorised Retailer(s) who will then provide the completed Health Form(s) to us.
4 HOW DO WE USE YOUR PERSONAL DATA?
4.1 We will only use your personal data when the law allows us to. We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please Contact Us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
4.2
|
Purpose/activity |
Type of Data |
Lawful basis for processing your personal data |
| To check that there are no obvious health conditions which might make the Products or treatments using the Products unsuitable for your use
|
Health Data
|
Your explicit consent to the processing of such data for the purposes specified |
| To facilitate the proper investigation into, and reporting of, any reactions which you have to a Product or treatment using a Product and, in some cases, for us to anonymise personal data to use in aggregated form for statistical and/or research purposes. | Health Data
Contact Data |
Where processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity
Necessary for our legitimate interests or that of a third party to compile aggregated anonymous information to assist in the reporting of reactions to any Products or treatments using the Products
|
4.3 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5 DISCLOSURES OF YOUR PERSONAL DATA
5.1 We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.1 above:
5.1.1 External third parties: Our Authorised Retailers, and the manufacturers of any Products, as well as service providers such as our insurers and legal advisers.
5.1.2 Corporate activity: Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
6 INTERNATIONAL TRANSFERS
We do not transfer any of your personal data to third parties located outside of the EEA.
7 DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8 HOW LONG WE KEEP YOUR PERSONAL DATA
We keep your personal data for no longer than is allowed under applicable data protection law and, in any case, no longer than the personal data is necessary for the purpose for which it was processed. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We also retain personal data if required by applicable law or regulation or is justified under applicable statutory limitation periods.
9 YOUR LEGAL RIGHTS
9.1 Under certain circumstances data subjects have rights under data protection law in relation to personal data, namely:
9.1.1 Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
9.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
9.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
9.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
9.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following circumstances: (a) if you want us to establish the data’s accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to be retained to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
9.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the personal data to perform a contract with you.
9.1.7 Withdraw consent at any time if and to the extent we are relying on consent as the legal basis to process your personal data. This will not affect the lawfulness of any processing of your personal data carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will let you know if this is the case at the time you withdraw your consent.
9.2 Exercising your rights. To exercise one or more of your rights in respect of your personal data, please contact us using the Contact Us details below. We will respond to your request(s) as soon as reasonably practicable, but in any case, within the legally required period of time. We remind you that you may contact the Authorised Reseller regarding their own data handling, including communications with them about those rights in respect of them.
9.3 Contacting the data protection supervisory authority. Data subjects have the right to make a complaint at any time to the data protection supervisory authority. The Irish supervisory authority for data protection issues is the Data Protection Commission (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commission so please contact us in the first instance using the information listed in Contact Us below.
9.4 Updating your personal data. It is important that the personal data we hold about you is accurate and current. Please keep us informed, using your account settings (if you have a user account on our website) or by using the Contact Us details below, if any of your personal data changes during your relationship with us.
10 CHANGES TO THIS NOTICE
We will change this Privacy Notice from time to time and any changes will be posted to the website. This version of the Privacy Notice was last updated on 13 November 2018 and historic versions can be obtained by contacting us using the Contact Us details below.
11 CONTACT US
If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us at : info@renaissanceproducts.com.